EN 10204: Inspection Document Types for Metallic Products

Quick Answer

EN 10204 is the foundational European standard for metallic product inspection documentation. Published by CEN (European Committee for Standardization) and adopted as a national standard across EU member states, it answers a deceptively simple question: who conducted the tests, and how independently were the results validated?

The standard was last revised in 2004 (EN 10204:2004), superseding the 1991 edition. It applies to all metallic products regardless of product form or material type — plate, pipe, bar, fittings, castings — and is referenced by virtually every European material standard and purchase specification.

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The Four Document Types

EN 10204 defines a hierarchy of four inspection document types. Each successive type increases the independence of validation and the traceability of the data.

Type 2.1 — Declaration of Compliance with the Order

Issued by: The manufacturer (commercial department or quality department).

Content: A statement that the products supplied comply with the requirements of the order, with no actual test data.

Typical use: Low-risk, non-critical commercial applications where the buyer accepts the manufacturer's declaration without supporting test evidence. Common for standard commodity items (bolts, standard fasteners, non-critical structural parts).

Key limitation: No actual test results are included. The document is a declaration, not a test report.

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Type 2.2 — Test Report

Issued by: The manufacturer (same party producing the goods).

Content: A statement of compliance plus actual test results based on non-specific inspection — meaning the tests may have been performed on material from the same production run or batch, but not necessarily the exact pieces being supplied.

Typical use: General structural steel, commercial-grade materials where lot traceability is not contractually required. Also used where the buyer wants to see typical test data but does not require product-specific certification.

Key limitation: The test results are not necessarily from the same heat or lot as the delivered material. Batch-level traceability only.

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Type 3.1 — Inspection Certificate

Issued by: The manufacturer's authorized representative — an inspector independent of the manufacturing department. This person is typically designated by the manufacturer's quality system but is organizationally separate from production.

Content: A statement of compliance plus actual test results from specific inspection of the delivered material. Results are traceable by heat/lot to the specific pieces supplied.

Typical use: This is the most commonly required document type in European pressure equipment, process piping, and structural applications. The Pressure Equipment Directive (PED 2014/68/EU) and most European project specifications require 3.1 as the minimum.

Key characteristic: The certifying inspector must be independent of production — they cannot be the production supervisor.

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Type 3.2 — Inspection Certificate

Issued by: The manufacturer's authorized representative AND an independent third party — either a customer's representative or an accredited inspection body (TÜV, Bureau Veritas, Lloyd's, SGS, etc.).

Content: Same as 3.1, but additionally countersigned by the independent party, who has witnessed or independently verified the tests.

Typical use: High-risk applications — nuclear components, safety-critical offshore structures, subsea equipment, Class 1 pressure vessels under PED, or any application where contractual or regulatory requirements mandate independent third-party verification.

Key characteristic: Dual signature. The independent inspector's name, organization, and signature must appear on the certificate alongside the manufacturer's representative.

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Summary Comparison Table

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What "Authorized Representative" Means

EN 10204 is precise about who can sign a 3.1 certificate. The authorized representative must be:

1. Employed by or contractually engaged with the manufacturer.
2. Formally designated by the manufacturer's quality system.
3. Organizationally independent of the production department — they must be able to reject material without commercial pressure from production management.

This last requirement is the critical one. A production manager cannot sign their own material's 3.1 certificate. The signatory must be in a quality, inspection, or technical role that reports independently.

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Certificate Content Requirements

EN 10204 specifies minimum content for each document type. For 3.1 certificates (the most common), the following must appear:

• Name and address of the manufacturer
• Name and address of the recipient (or "as per purchase order")
• Description of the products (standard reference, grade, dimensions, quantity)
• Order reference (customer PO number)
• Statement of compliance with the relevant standard and order
• Test results (chemistry, mechanical properties, any additional tests)
• Heat number or batch number
• The authorized representative's name, signature, and — where required — stamp

Missing any of these elements makes the certificate non-compliant with EN 10204, regardless of how good the test data is.

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Common Mistakes in EN 10204 Certificates

1. Wrong document type for the application Specifying a 2.2 report when PED requires 3.1 is a non-conformance. Always verify the required document type before placing the purchase order.

2. Missing heat/lot traceability A 3.1 certificate that does not explicitly link test results to the heat number of the delivered material fails the traceability requirement.

3. Unsigned or improperly identified representative The 3.1 signatory must be identified by name and role, not just a stamp. An anonymous stamp is not sufficient.

4. Citing a superseded edition Some older MTCs still reference EN 10204:1991 (the previous edition). The 2004 edition is current; check with the buyer whether historical edition is acceptable.

5. Combining non-specific and specific results Some mills mix 2.2-level (batch) chemistry with 3.1-level (specific heat) mechanical results. The resulting document is effectively a 2.2, not a 3.1.

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EN 10204 in the Context of Other Standards

EN 10204 defines the format and traceability of the inspection document. It does not define the acceptance limits — those come from the product standard (e.g., EN 10028-7 for flat products, EN 10216 for tubes). The two standards work together: the product standard tells you what to test and what limits to apply; EN 10204 tells you what kind of document must certify the results.

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Frequently Asked Questions